In September 2010, ICANN conducted the first formal Inter-Registrar Transfer Policy ("IRTP") audit to assess registrar compliance with the policy, following a beta audit conducted earlier in May 2010. The report on the formal audit was posted in December 2010 at ICANN Contractual Compliance's webpage: http://www.icann.org/en/compliance/reports/irtp-audit-report-13dec10-en.pdf [PDF, 298 KB].
In this formal audit, we found nine (9) registrars deemed non-compliant with the IRTP. However, one of them turned out to be caused by a confusion over the use of terminology, which has since been clarified so the total number of non-compliant registrars now stands at eight (8).
On 20 January 2011, all 8 registrars were issued a non-compliance notice. Each notice set out the specific reasons for ICANN's assessment and requested the registrar to submit a proposed corrective action plan by 15 February 2011. Except one registrar that has not responded to ICANN, 7 registrars have responded with proposed action plans on or before the deadline of 15 February and all of them have implemented or in the process of implementing their proposed action plans.
Summary of ICANN's assessment and registrars' responses:
|Rr #||Rr Role||Reasons for ICANN's Assessment||Corrective Action Plan Proposed||Corrective Action Plan Implemented|
|1||Losing registrar||Wrongfully denying transfer requests based on non-payment of fees for pending or future registration periods during the Auto-Renew Grace Period||Yes||Yes|
|2||Losing registrar||Wrongfully denying transfer requests on the basis that there was no affirmative confirmation from registrants||Yes||Yes|
|3||Gaining registrar||Initiating transfers without FOAs||No||No|
|4||Gaining registrar||Initiating transfers without FOAs||Yes||Yes|
|5||Registrar of record||Employing "mechanism for complying with a Registered Name Holder's request to obtain the applicable "AuthInfo Code" that is more restrictive than the mechanisms used for changing any aspect of the Registered Name Holder's contact or name server information."||Yes||Yes|
|6||Registrar of record||Failure to provide "AuthInfo Code" within 5 calendar days due to reseller issues||Yes||TBA|
|7||Registrar of record||Failure to provide "AuthInfo Code" within 5 calendar days due to reseller issues||Yes||March 2011|
|8||Registrar of record||Failure to provide "AuthInfo Code" within 5 calendar days due to reseller issues||Yes||Mid March 2011|
The IRTP is intended to provide domain portability and better consumer choice. Consistent with this policy goal, ICANN will continue to closely monitor and actively enforce registrar compliance with the IRTP To this end, in addition to conducting regular audits, we will continue to follow up with registrars regarding complaints or alleged violations that are brought to ICANN's attention (for example, through ICANN's consumer complaint ticketing system http://reports.internic.net/cgi/registrars/problem-report.cgi).
We hope these ongoing compliance efforts will improve registrars' overall understanding of and better compliance with their obligations under the transfer policy.